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WESTERN MINING ACTION PROJECT <br />Roger Flynn, Esq., <br />Jeffi-ev C. Parsons, Esq. <br />P.O. Box 349 <br />440 Main Street, Suite 2 <br />Lyons, CO 80540 <br />(303) 823-5738 <br />Fax (303) 823-5732 <br />wmapa;i corr. <br />via email <br />July 24, 2009 <br />Valois Shea <br />U.S. Environmental Protection Agency Region 8 <br />8P-W-GW, UIC <br />1595 Wynkoop Street <br />Denver, CO 80202 <br />shea.valois Wepa.„ov <br />RE: Proposed Underground Injection Control Program (UIC) Permit (Permit Number: <br />C051237-08412). <br />Dear Ms. Shea, <br />Thank you for the opportunity to comment on your agency's proposal to issue an <br />Underground Injection Control Program (UIC) Permit (Permit Number: C051237-08412)' for <br />Powertech (USA) Incorporated's proposed aquifer pump test in the Fox Hills Aquifer in Weld <br />County, Colorado. As discussed herein, the draft permit cannot be issued as proposed. At a <br />minimum, substantial additional information is required to demonstrate the ability of the permit <br />applicant to protect underground sources of drinking water. This information includes additional <br />baseline data on the water quality of both the injectate and the receiving water. In addition, the <br />permit applicant should be required to demonstrate that the substantial historic exploration <br />drilling in the area of the proposed permit will not result in contamination of adjacent aquifers, <br />including underground sources of drinking water. Lastly, the EPA's permit processing exercise <br />should be better coordinated with the required state permitting process for the proposed <br />underground injection activities. <br />1 We note that various permit numbers are used in various documents, making it unclear to the public as to which <br />permit is under review. The Public Notice and Statement of Basis and Purpose show permit No. C051237-08412, <br />whereas the Draft Permit cites permit No. C051237-08408. Still further, the text of the Draft Permit states that <br />"[t]he EPA permit number the UIC Program Director ... has assigned to this permit is C05 1 23 7-08404." Draft <br />Permit at 2. Lastly, the bottom margin of each page of the Draft Permit lists "Petroglyph Energy, Inc., UIC Class V <br />Permit No. C051221-00000." Thus, in various places, the EPA has listed no less than 4 different permit numbers in <br />the materials. At a minimum, this is confusing to the public, and at worst, renders the public notice insufficient, and <br />requires re-notice of the permit application to the public.